BALDWIN HARDWARE CORPORATION AND SBD PROPERTY HOLDINGS, LLC (COLLECTIVELY RESPONDENT ) OPERATED A STORAGE FACILITY WITHOUT HAVING A PERMIT OR INTERIM STATUS. RESPONDENTS STORED NON-CONTAINERIZED LEAD-CONTAMINATED HAZARDOUS WASTE ON THE FLOORS OF THE FACILITY AND ALSO STORED LEAD-CONTAMINATED HAZARDOUS WASTE FOR PERIODS GREATER THATN 90 DAYS ON MULTIPLE OCCASIONS. RESPONDENTS FAILED TO MAINTAIN AN INSPECTION SCHEDULE, KEEP ADEQUATE RECORDS DOCUMENTING INSPECTION FINDINGS, AND FAILED TO PERFORM ADEQUATE INSPECTIONS IN ORDER TO IDENTIFY AND REMEDY FACILITY MALFUNCTIONS. FOR THESE REASOSN AND MORE, THE RESPONDENTS FAILED TO MAINTAIN AND OPERATE THE FACILITY IN A MANNER THAT MINIMIZED THE RISK OF RELEASE OF HAZARDOUS WASTE INTO THE ENVIRONMENT AND POSED A RISK TO THE ENVIRONMENT AND HUMAN HEALTH.